ref: letter – 25 june 2008 p0106-02 · 2013-07-26 · ref: letter – 25 june 2008 p0106-02 page...

Additional information requirements for the EPA – regarding the new IPPCL application:

Ref: Letter – 25 June 2008 P0106-02

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1. Oil Interceptor - Classification of oil interceptors There are 4 Interceptors on the surface water drainage lines at the facility marked as INT on

the attached Site Surface Water Layout Drawing (Attachment A: D100/001). The

interceptors are located on the discharge from the licensed discharge points SW1 and SW2

and also at a location upstream of SW1 and on SW3 discharge point. While the detailed

design specifications were not found in the archives from the installation date of 1995-1996,

information sourced from the Consulting Engineers who assisted with the specifications was

obtained. From this information, the main interceptors on SW1 and SW2 are three chamber

Class 1 Petrol Interceptors each of capacity 5000litres.

The area served by a Class 2 Interceptor (SW3) is a concrete surfaced area at the rear of the

Metal Parts Building. There is no potential for significant contamination of surface water in

this area because, aside from incoming materials, the area is used only for storage of empty

transformers and scrap metal. Although incoming deliveries are routed across this area,

vehicles do not routinely park there and do not remain for extended time periods.

ENVA – Formerly Atlas Oils is engaged twice a year to clean out the interceptors and they

agree with this conclusion. The design specification sourced from Garland Engineers is

attached for information – Attachment B SK-1

Location of Interceptor Class Located in the back yard - #1

Class 1 – Three chambers

Located in the back yard - #2

Class 2 – One chamber

Prior to emission to SW-1 -#3


Prior to emission to SW-2 - #4


Reference attached drawings

� D100/001 detailing the location of the oil interceptors on-site – Attachment A

� Drawing Number SK-1, detailing the type of interceptor used – Attachment B

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2. Update to Trade Effluent Sewer to include SE-2 Reference attached drawing:

� D100/001 highlighting the location of the SE-2 – Attachment C & Attachment D

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3. Emissions to Air - Emissions to Atmosphere from E-Coat process The painting process consists of 3 stages – Pre-Treatment, E-Coat and Powder Coat. The Pre-Treatment stage involves immersion of parts in baths

containing surfactant cleaning solutions, alkaline cleaners, water and a phosphating solution. The temperature of the baths is at ambient (unheated) to a

maximum of 65-75oC (Alkaline Cleaner Bath) and 45-55oC (Zinc Phosphate Bath). The E-Coat stage consists of immersion of parts in an E–Coat

solution at 30oC followed by water rinses and then drying of parts in the Stoving/Curing Oven. An extract system collects water vapour for discharge

above the level of the roof via 3 flues. The emissions from the Stoving/Curing Oven are released through Emission Points A26A, A26B, A26C and these

emissions are monitored annually. Emissions from the Powder Coat Oven (A27A, A27B) are also monitored annually. The emissions from the Pre-

Treatment and part of the E-Coat Stage of the paint process are not significant. The chemical composition of the solutions was reviewed and due to the

non-volatile constituents as well as low temperatures, emissions would not contain harmful constituents.

E-Coating Process

Tank Treatment3 Areas

1.Pre-Treatment

2.E-Coating

3.Powder Coating

Coating electrically deposited onto the surface

of the steel and rinsed

Stage 11: E-coat analyte

Consituents listed:Demin waterEC-solvent: 2-(2-butoxyethoxy ethanol 100%, Solvent : 2-butoxyethanol 49.5%Pigment pasteEC3000 Resin Aqua EC2000/3000Neutralizing agent: Acetic acid 50%Anti-crater agent: formic acid 1.7%, 1-methoxy2-propanol 1.3%Edge protection agent: 2-butoxyethanol, 1-methoxy-2-propanolThickness additive: butanol 50%, sec-butanol 50%

Stage 12: UltrafiltrationStage 13: UltrafiltrationStage 14: Ultrafiltration

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3. Emissions to Air - Emissions to Atmosphere from E-Coat process contd: Diagram of the Stoving (E-coat) and Curing (Powder coat) oven – emission points labelled:

POWDEROVEN

E-COATOVEN

Oven ExhaustA27A

Oven ExhaustA26A

ENTRY OVEN EXHAUST(Common To Both Ovens)A27B

ENTRY OVEN EXHAUST(Common To Both Ovens)A26B

AIR SEAL TO ATMOSPHEREA26CSTAIRS STAIRS

OVENENTRY &EXIT THISEND

A27A

A26A

A27B

A26B A26C

AUTOFINORGINALISSUE

OVEN EXHAUST POSITIONS

PAUWELS TRAFO

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4. Table E.1 (i) for all boiler emissions

Emission Point: Emission Point Ref. No:

A21

Location:

AP Building Domestic Boiler

Grid Ref. (12 digit, 6E,6N):

243706E, 304218N

Vent Details

Diameter: 0.15m

Height above Ground(m): 1m

Date of commencement of emission:

1977

Characteristics of Emission:

Boiler rating Steam Output: Thermal Input:

N/A kg/hr

MW Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content:

Oil kg/hr < 1% S

NOx 300 mg/Nm3

0oC. 3% O2(Liquid or Gas), 6% O2(Solid Fuel) Maximum volume* of emission

2000 m3/hr 0oC, 3 % O2 (liquid or gas), 6 % O2 (solid fuel)

Temperature

236oC(max) 180oC(min) 200oC(avg)

* Volume flow limits for emissions to atmosphere shall be based on Normal conditions of temperature and pressure, (i.e. 0oC,101.3kPa), dry gas; 3% oxygen for liquid and gas fuels; 6% oxygen for solid fuels. (i) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up/shutdown to be included): Periods of Emission (avg) 60 min/hr 12 hr/day 120 day/yr

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Table E.1 (i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point: Emission Point Ref. No:

A22

Location:

Metal Parts Building


-

Vent Details

Diameter: 0.2m

Height above Ground(m): 3


1992



kg/hr MW

Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content:

OIL

kg/hr < 1% S

NOx 100mg/Nm3


500m3/hr 0oC, 3 % O2 (liquid or gas), 6 % O2 (solid fuel)

Temperature



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Table E.1 (i) BOILER EMISSIONS TO ATMOSPHERE (1 Page for each emission point) Emission Point:

Emission Point Ref. No:

A30

Location:

Archives Building, Canteen Boiler


Vent Details

Diameter: 0.11

Height above Ground(m): 3


2004



kg/hr

0.025 MW Boiler fuel Type: Maximum rate at which fuel is burned % sulphur content:

GAS kg/hr

< 0.2% S NOx < 160 mg/Nm3


m3/hr < 3 0oC, 3 % O2 (liquid or gas), 6 % O2 (solid fuel)

Temperature



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5. Status of Emission point A15 Emission point A15 (Final Spray Exhaust) was dismantled completely in April 2008. The booth

was very infrequently used. From our previous Annual Environmental Report submissions you will

have noted the Final Spray Exhaust (A15) was not operational during annual monitoring only once

since 2002. The paint waste was removed stored in barrels and is currently awaiting Hazardous

waste disposal.

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6. Emissions to Air – Table E.1(ii) and E.1(iii)

TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point)


A4A

Source of Emission:

Shotblast

Location:



243856E, 304198N

Vent Details Diameter:

Height above Ground(m):

0.5m 11m

Date of commencement:

1987


(i) Volume to be emitted:

Average/day 136,000 Nm3/d Maximum/day 136,000 Nm3/d

Maximum rate/hour 8,500 Nm3/h Min efflux velocity 5 m.sec-1

(ii) Other factors

Temperature 25oC(max) oC(min) 20oC(avg)

For Combustion Sources: Volume terms expressed as : � wet. � dry. ________%O2

(iii) Period or periods during which emissions are made, or are to be made, including daily or seasonal variations (start-up /shutdown to be included): Periods of Emission (avg) 40 min/hr 16 hr/day 220 day/yr

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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemica l characteristics of the emission (1 table per emission point) Emission Point Reference Number: A4A Old Shotblast

Parameter Prior to treatment(1) Brief As discharged(1)

mg/Nm3 kg/h description mg/Nm3 kg/h. kg/year

Avg Max Avg Max of treatment Avg Max Avg Max Avg Max

Particulate 20 50 0.16 1.5 Reverse Jet Cleaning Cartridge 5 10 0.04 0.08 141 282

1. Concentrations should be based on Normal conditions of temperature and pressure, (i.e. 0oC,101.3kPa). Wet/dry should be the same as given in Table E.1(ii) unless clearly stated otherwise.

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A4B

Source of Emission:

New Shotblast

Location:



243876E, 304221N



0.3m 11m


1997





(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical ch aracteristics of the emission (1 table per emission point) Emission Point Reference Number: A4B New Shotblast




Particulate 20 50 0.34 0.85 Reverse Jet Cleaning Cartridge 5 10 0.085 0.170 299.2 598.4


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A29

Source of Emission:

New Drying Oven

Location:



243747E, 304139N



0.3m 11.5m


1997





(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical ch aracteristics of the emission (1 table per emission point) Emission Point Reference Number: A29 New Drying Oven_________




Organics None 2 10 0.02 0.10 105.6 528


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A26A

Source of Emission:

Stoving / E-Coat Oven

Location:



243909E, 304176E



0.4 10m


1997





(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical cha racteristics of the emission (1 table per emission point) Emission Point Reference Number: A26A Stoving / E-Coat Oven___




Organics None 2 10 0.02 0.10 105.6 528


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A26B

Source of Emission:


Location:



243919E, 304172N



0.4m 10


1997




Maximum rate/hour 10,000 Nm3/h Min efflux velocity 4m.sec-1

(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical ch aracteristics of the emission (1 table per emission point) Emission Point Reference Number: A26B Stoving / E-Coat Oven




Organics None 2 10 0.02 0.10 105.6 528


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A26C

Source of Emission:


Location:

Powder Oven


243921E, 304171N



0.3m 10m


1997





(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical ch aracteristics of the emission (1 table per emission point) Emission Point Reference Number: A26C Stoving / E-Coat Oven




Organics None 5 10 0.05 0.10 264 528


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A27A

Source of Emission:

Curing / Powder Oven

Location:

Powder Oven


243903E, 304174N



0.3m 10m






(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical ch aracteristics of the emission (1 table per emission point) Emission Point Reference Number: A27A Curing / Powder Oven




Organics None 5 10 0.05 0.10 264 528


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A27B

Source of Emission:

Curing / Powder Oven

Location:

Tanking Area


243920E, 304176N



0.18m 10m


1997





(ii) Other factors




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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical c haracteristics of the emission (1 table per emission point) Emission Point Reference Number: A27B Curing / Powder Oven




SO2

NOx

CO

None

None

None

1.75

8.1

123

4.5

100

406

0.014

0.065

0.985

0.036

0.160

3.25

73.9

343

5200

190

845

17160


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7. Emissions to Air – Classification of Emission Points

Emissions to atmosphere from all emission sources are monitored annually. Monitoring reports

from 2000-2007 have been reviewed and the data shows that emission levels are consistently at or

below the limit of detection for most parameters on most occasions. The BAT Guidance Note for

Non Ferrous Metals and Galvanising gives guidance on the expected BAT emission levels for all

parameters which are monitored and the levels are consistently below the BAT level and are

typically less than 10-20% of the relevant BAT Limit. It is therefore reasonable to classify all of the

emission points as Minor Emission Points. The Guidance Note suggests that when abatement

systems are installed that the emissions should be considered as Major Emission Points. The two

Shotblasts (Emission Points A4A and A4B) have Reverse Jet Cleaning Systems fitted to collect

dust from the shotblasting apparatus. Review of monitoring data for these emission points for 2000-

2007 suggests that the emissions from the systems are always significantly lower than the BAT

Guidance levels. It is therefore our opinion that these two emission points should also be classified

as Minor Emission Points.

8. Emissions to Air – Abatement system on A4B

The abatement system installed in the New Shotblast (Emission Point A4B) is a Reverse Jet Filter

Cleaning System. Dust collected in the system is collected in a sealed drum under the unit. The

same type of abatement system is installed on the Old Shotblast (Emission Point A4B). There are 9

and 20 filter cartridges installed in the abatement units at Emission Points A4A and A4B,

respectively.

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TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A4A Shotblast ______

Control1 parameter Equipment 2 Equipment maintenance Equipment calibration Equipment back-up

Pressure Differential Pressure Gauge Cleaning Annual

Control1 parameter Monitoring to be carried out3 Monitoring equipment Monitoring equipment calibration

Differential Pressure Continuous Differential Pressure Gauge Annual

1 List the operating parameters of the treatment / abatement system which control its function. 2 List the equipment necessary for the proper function of the abatement / treatment system. 3 List the monitoring of the control parameter to be carried out.

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TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A4B New Shotblast


Pressure Differential Pressure Gauge Cleaning Annual -


Differential Pressure Continuous Differential Pressure Gauge Annual


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9. Burn-off oven – Description of process This is a very simple process, non-conforming parts which have passed through the paint

system are introduced manually. It is important to reach a high temperature in order to

remove the paint, thus the temperature is continuously monitored during operation. A copy

of the specification of the burners used is attached – Attachment D. The emissions are not

abated and concentration of substances present are low. The emissions are minor as is

evident from previous monitoring data.

10. Treatment in the Burn-off Oven

The primary purpose of the Burn-off oven is to remove powder paint. The Powder painted

tanks and paint system load bars which are incorrect i.e. powder not aesthetically correct,

parts missing from the tank etc are ‘burned-off’. The oven is gas-fired thus some

combustion gas is emitted, which include Carbon Monoxide, Carbon Dioxide and Nitrogen

Oxides. All parts are 100% reused. The waste generated i.e. ash is collected in barrels and

disposed off.

11. Coating materials which undergo treatment in the burn-off oven

The non-conforming parts which undergo treatment in the Burn-off oven have passed

through the cleaning , zinc phosphating, E-coat and Powder coat processes. The parts have

also passed through the E-coat and Powder coat stoving oven and therefore the coating

materials are dry and solid. Therefore there are no volatile constituents remaining. A review

of all the materials used in the above processes was performed, the constituents remaining

on the parts prior to Burn-off were identified and are listed in the table below.

Process Stage Chemical Used (Constituents listed) Pre-treatment Conditioning rinse • Prepalene X - Zn3-phosphate 4H20 <25%.

Zinc Phosphate • Novaphos Z616 CMI- Phosphoric acid 10-20%,

Nickel nitrate - 5%max • Grenodine958 – Phosphoric acid 10-20%, Nickel

Nitrate 2-4%, Fluorosilicic acid 1-2% Electro-coat E-coat bath • Pigment pasteEC3000 –

• Resin Aqua EC2000/3000: Powder coating

Powder spray booths Auto & Manual

• Main constituent: Multi functional glicidyl esters 1-5%.

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12 Burn-off oven usage

Each ‘burn-off’ run is monitored using a chart recorder – this indicates the temperature and

time of each operation. During the previous calendar year i.e. 2007, the burn-off oven was

operational for a total of 234 hours (approximately 9.75 days). Normal usage is

approximately 8 hours per burn-off.

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13. Burn-off oven TABLE E.1(ii) MAIN EMISSIONS TO ATMOSPHERE (1 Page for each emission point)


A28

Source of Emission:

Burn Off Oven

Location:



243956E, 304217N



0.11m 11m


1997





(ii) Other factors


For Combustion Sources: Volume terms expressed as : � wet. � dry. ___3____%O2


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TABLE E.1(iii): MAIN EMISSIONS TO ATMOSPHERE - Chemical ch aracteristics of the emission (1 table per emission point) Emission Point Reference Number: A28 Burn Off Oven




Heavy Metals

HCL

Organics

None

None

None

0.08

2.5

2

0.22

8.5

5

7.7x10-5

0.0025

0.002

2.2x10-4

0.0085

0.005

0.407

13.2

10.6

1.16

44.9

26.4


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TABLE F.1(i): ABATEMENT / TREATMENT CONTROL Emission point reference number : A28______


Temperature Thermocouple

Recorded

Cleaning Annual


Temperature Continuous Thermocouple

Recorded

Annual


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14. Best Available Techniques (BAT) The Pauwels Trafo Ireland Ltd facility is subject to the requirements of the IPPC Directive and is

licenced by the EPA under the IPC/IPPC Licensing regime. Council Directive 96/61/EC on

integrated pollution prevention and control, the IPPC directive, defines a system of permitting for

certain types of activity. The purpose of the Directive is to achieve integrated prevention and

control of pollution arising from the activities listed in Annex I of the Directive, leading to a high

level of protection of the environment as a whole. The permits for activities listed in Annex I of the

IPPC Directive must be based on the concept of Best Available Techniques, or BAT, which is

defined in Article 2 of the IPPC Directive as follows:

“best available techniques shall mean the most effective and advanced stage in the development of

activities and their methods of operation which indicate the practical suitability of particular techniques

for providing in principle the basis for emission limit values designed to prevent and, where that is not

practicable, generally to reduce emissions and the impact on the environment as a whole”

“techniques shall include both the technology used and the way in which the installation is designed,

built, maintained, operated and decommissioned”

“available techniques shall mean those developed on a scale which allows implementation in the

relevant industrial sector, under economically and technically viable conditions, taking into

consideration the costs and advantages, whether or not the techniques are used or produced inside

the Member State in question, as long as they are reasonably accessible to the operator”.

'best` shall mean most effective in achieving a high general level of protection of the environment as

a whole.”

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14. Best Available Techniques (BAT) contd: In determining the best available techniques, the Directive specifies that special consideration must

be given to the items listed in Annex IV of the Directive as follows, “bearing in mind the likely

costs and benefits of a measure and the principles of precaution and prevention”:

1.the use of low-waste technology;

2.the use of less hazardous substances;

3.the furthering of recovery and recycling of substances generated and used in the process and of

waste, where appropriate;

4.comparable processes, facilities or methods of operation which have been tried with success on

an industrial scale;

5.technological advances and changes in scientific knowledge and understanding;

6.the nature, effects and volume of the emissions concerned;

7.the commissioning dates for new or existing installations;

8.the length of time needed to introduce the best available technique;

9.the consumption and nature of raw materials (including water) used in the process and their

energy efficiency;

10. the need to prevent or reduce to a minimum the overall impact of the emissions on the

environment and the risks to it;

11. the need to prevent accidents and to minimize the consequences for the environment;

12. the information published by the Commission pursuant to Article 16 (2) or by international

organizations.

The final decision on BAT rests with the Member State because Article 9 of the Directive

establishes that the licensing authority must take account of “the technical characteristics of the

installation concerned, its geographical location and the local environmental conditions”.

The Final Draft BAT Guidance Note on Best Available Techniques for Non-Ferrous Metals and

Galvanising is the relevant Guidance Note for the Pauwels Trafo facility. The Guidance Note

covers several sectors which includes “3.9 Boilermaking and the manufacture of reservoirs, tanks

and other sheet metal containers where the production area exceeds 500 square metres” which is

the Sector under which Pauwels Trafo are to be licenced. A review of site activities with specific

reference to this Guidance has been completed to ensure that Best Available Techniques are being

employed at the facility.

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14.1 BEST AVAILABLE TECHNIQUES (BAT) A SSESSMENT

14.1.1 Management Systems

Pauwels Trafo are accredited to ISO 14001 (2004) and have a strong Environmental Management System in

place. Environmental Policy Statement and commitment from Management to manage the environmental

impacts of the facility is a key feature of the system. As part of the Environmental Management System

Pauwels have implemented procedures to control the introduction of new products/new processes. These

procedures ensure approval from H&S, Environment and Quality departments prior to the implementation of

the change. They also ensure review of material specifications by our Design department and input from the

Engineering department where necessary.

14.1.2 Minimisation of Energy Use

Proactive Energy Management procedures are employed at the facility. Fans are switched off when not in

use, and regular reminders about energy conservation are issued to all personnel. One of the main projects

included in this years EMP is an Energy Audit. Other initiatives which have led to enhanced energy

management at the facility in recent years are enumerated as follows.

14.1.3 EMAT – Energy Monitoring System

The system was installed, to track usage of Electricity in the following areas/machines:

� Electricity at the Main meter

� Bucher Machine

� Step-lap

� Annealing Ovens

14.1.4 Sensor lighting

Installed at various areas throughout the Plant. Lights are motion controlled, they are 250 Watts v’s

450 Watts (old type) and also give out the same light strength. They are placed in areas where

people are constantly on the move in and out of:

� Maintenance offices / workshop

� Canteens

� Final Assembly area

� Over certain machines

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14.1 Best available techniques (BAT) Assessment contd:

14.1.5 Minimisation of water use

Water is not used to a significant extent in the Process. Water is employed in the Painting Process but this

water is replenished and reused where possible. The overall volume of water used is small. Projects are

continuously introduced aimed at further reducing water usage.

During 2006 the following new materials were introduced which led to reduced water usage:

� Substitution of Fixodine L refiner with Prepalene X and Additive 4977B – This is an upgraded

material, which has a longer shelf life than the material previously used. This material has a higher

stability against bath aging, thus in theory increase the amount of time our baths may be used. In turn

reduces the amount of chemical usage and thus significantly reducing water usage.

14.1.6 Minimisation of the Use of Raw Materials

A detailed inventory of materials is maintained and regular reviews of material usage are

conducted. Projects are regularly undertaken to ensure that materials use is minimised. Examples of

successful projects are listed below.

� Substitution of Novaclean A cleaner with Ridosol 525 in paint area - This is an upgraded material,

which is twice as active as the current chemical – thus the usage will reduce by 50%.

14.1.7 Minimisation of emissions

Emissions to air are minor at the facility. Temperatures are reduced in the E-Coat process leading to

lower potential for emissions and effective cleaning and pre-treatment systems are in place.

14.1.8 Waste management

Proactive waste minimisation programmes are in place throughout the facility. In 2006 the company

bought a Baler for cardboard and plastic. This led to increased recycling of cardboard 11.5Ton

(1999) to 17.7Ton (2006) and plastic 0Ton (1999) to 9.7Ton in 2006.

14.2 CONCLUSION

In conclusion a review of activities has been completed and with reference to the relevant BAT

Guidance Note, we are satisfied that BAT is being applied at the facility. As technology develops,

activities are constantly reviewed to ensure that BAT is maintained.

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15. Materials Table G.1(I) Details of Process related Raw Materials, Intermediated, Products, Etc., used or generated on the site

Odour EU Lists I ans II (Tick and specify Group / Family Number)

Dangerous Substances Directive 76/464/EEC Groundwater Directive 80/68/EEC

Ref No. / Code Material / Substance Odourous Yes / No Description

Threshold ug/m3 List I List II +129 List I List II

(PO12.02) 0651-918 Alugard 16 / Hydrochloric Acid Solution for metal precipitation Yes Pungent odour Not specified Autobooth P27 - contents - Sodium Hydroxide No No No No - Sodium Carbonate No No No No

(PO26.00)

- Sodium Metasilicate No No No No No (PO30) Buffer Solution- pH 10.00 No No No No (P031) Buffer Solution - pH 4,00 No No No No (P032) Buffer Solution - pH 5,00 No No No No (P033) Buffer Solution - pH 7.00 No No No No

(PO84) Buffer Solution - pH 9,00 No No No No No

(PO39) 0651-912 Caustic Liquor 20% w/v No Negligible Not specified No No No No

(PO56.01) 0651-862 EC Neutralising Agent Not specified No No No No

EC Solvent - Contents Ethylene Glykolmonobutylether Yes, 7 No No No Diethylene Glycolmonobutylether Yes, 7 No No No Glykole Yes, 7 No No No

(PO57.01) 0651-855

Butanol Not specified Yes, 7 No No No

(PO61.00) EDTA Reagent Powder Pillows No None No No No No

(PO62.00) Macpherson Eggshell and Bases Not specified Yes, 7 No No No

0651-928 Foam block 210S Yes Odour characteristic No No No No

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Colormix - White Cap - contents Acetone Yes, 7 No No No Butanone Yes, 7 No No No

(PO93.00)

Dimethyl Ether Propellant Yes Pleasant, agreeable Not specified Yes, 7 No No No

(PO94.01)0651-936 Granodine 958 Replenisher Yes Slight, acidic Not specified Yes, 4 Yes, 1,5 No No

(PO95.00) Spraymatch (Blue Cap) Yes Characteristic Not specified Yes, 7 No No No

(P112.00) Nitrogen No No odour warning Not specified No No No No

(P107.00) Macpherson Gloss and Bases Not specified Yes, 7 No No No

P111.01 (0652-050) Multi-Solve Not specified Yes, 1,4 No Yes No Novaclean 177D No No Potassium Hydroxide No No No No (P114.01) 0651-932

Sodium Hydroxide Yes Slight Not specified No No No No

Novaclean A Sodium Hydroxide (P115.01)0651-930

Non-ionic surfactants No longer in use

Novamax Accelerator 13L (P117.01)0651-938

Sodium Nitrite No None No No No No

Novamax Additive 100L (P118.01)0651-940 Sodium Hydroxide No longer in use

Novaphos Z616 CMI Phosphoric Acid No Yes, 5 No Yes (P120.01)0651-934

Nickel nitrate Yes Slight Not specified Yes, 4 Yes, 1, 5 No No

Nytro 10BN Hydrotreated Light Naphthemic Distillate Yes, 7 No No No P122.00

Clay Treated Light Naphthenic Distillate No Odourless Yes, 7 No No No

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Nytro 10 GBN P123.01 (0680-001)

Hydrotreated Light Naphthemic Distillate No Odourless Yes, 7 No No No

Nytro 10 XT Hydrotreated Light Naphthenic Distillate Yes, 7 No No No P124.00 (0680-075)

2,6-ditertiary Butyl-4-Methyl Phenol No Odourless Yes, 7 No No No

P133.00 Phenolphthalein Solution Not specified No No No No

Phosphate Standard Solution Potassium Phosphate Monobasic No Yes, 5 No Yes P135.00

Demineralized Water No None No No No No Phos Ver 3 Phosphate Reagent Powder Pillows Ascorbic Acid No No No No Potassium Pyrosulfate No No No No

P136.00

Sodium Molybdate Not specified No Yes, 1 No No

P139.00 Potassium Persulfate for Phosphonate No longer in use

P147.01 Flawfinder Developer Spray Yes Characteristic Not specified No No No

Flawfinder Dye Penetrant Carbon Dioxide Aerosol Propellant No No No No Isoparaffinic Hydrocarbon Yes, 7 No No No

P148.01

White Mineral Oil Yes Characteristic Not specified Yes, 7 No No No

ROCOL Penetrating Spray Odourless Kerosene Yes, 7 No No No P149.00

Carbon Dioxide Aerosol Propellant Yes Characteristic Not specified No No No No

P150.00 Rocol RTD Liquid Yes Characteristic Not specified No No No No

P152.00 Rocol Lmtd Yes Characteristic Not specified No No No No

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P160.00 Sigmafast Enamel Yes Characteristic Not specified NOTE IN USE

P163.01 Sodium hydroxide No Odourless No No No No

P167.01 Sulphamic acid GPR No Odourless No No No No

P169.01 Sulphuric acid 0.05mol/l (0.1N) No Odourless No No No No

Thinner 1031 Xylene,mixture of isomers Yes, 7 No No No Ethyl benzene Yes, 7 No No No n-Butanol Yes, 7 No No No

P182.01

1-Methoxy-2-propanol Not specified Yes, 7 No No No

P185.00 Machinery Enamel Not specified Urogen and Roofkote Thinners Low Boilint Point Naphtha Yes, 7 No No No Light Arom. 70-90% Yes, 7 No No No

(P188.01)0651-540

Einecs Yes Perceptible odour Not specified No No

Urogen Epithane Zinc-AL Primer (P196.01)0651-548

2-Methoxy-1-Methylethyl Acetate Yes Perceptible odour Not specified Yes, 7 No No No

(P210.01)0651-915 Hydrochloric acid Yes Pungent odour Not specified No No No No

P215.01 Nitric acid GPR Yes Pungent odour Not specified No No No No

(P224.02)0651-922 Phosclear 401 Not specified No No No No

P233.00 Metaflux 70-38 Galva-Protect Yes Characteristic NO LONGER IN USE

P236.01(0651-865) ET-Emulgator Agent Not specified No No No No

P239.01(0651-870) EC Anti-Crater Agent Not specified No No No No

P244.00 Liquified Petroleum Gas or Propane Not specified No No No No

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P247.00 Methyl ethyl ketone Yes Sweetish odour -

alcohol-like Not specified Yes, 7 No No No

(P250.01) 0651-830 Aqua-EC 2000/3000 Not specified Yes, 7 No No No

P252.01 Interpon Powder Coating Not specified Yes, 7 No No No

(P253.01) 0651-875 Electrocoate Edge Protection Agent Not specified Yes, 7 No No No

(P258.00) 0651-220 Galvatect Yes Ketone solvent Not specified Yes, 7 No No No

Upol Custom Can Aerosol Acetone Yes, 7 No No No P272.00

DimethylEther Yes Characteristic Not specified Yes, 7 No No No

(P284.00)0651-915 Hydrochloric acid Yes Pungent odour Not specified No No No No

P289.00 Acetylene Yes

Poor warning properties at low concentrations -

Garlic-like Not specified No No No No

P299.01 Interpon Powder Coating Not specified No No No No

(P307.01)0651-872 Electrocoat EC-Disinfection Agent Yes Typical Not specified Yes, 7 Yes, 2 No No

(P331.00)0651-560 Urogen Gloss RAL 7033-1503 Yes Characteristic Not specified Yes, 7 No No No

(P332.00)0651-551 Urogen Gloss Clear-RAL-ALL COLOURS Yes Characteristic Not specified Yes, 7 No No No

P333.00 (0651-542) Urogen Gloss Activator (Roofkote) Yes Characteristic Not specified No No No No

P335.00 Activator for Urogen Epithane Sin-Al Primer Yes Perceptible odour Not specified No No No No

(P338.00)0651-852 Aqua-EC 3000 Pigment Paste Black Yes Typical Not specified Yes, 7 No No No

Ridosol 525

Non-ionic surfactant No No No No (P342.00) 0651-931

Anionic surfactant Yes Slight,

characteristic Not specified No No No No

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Prepalene X (P356.00)0651-947

Phosphates No No valuation No Yes, 5 No Yes Additive 4977B

(P357.00)0651-948 Potassium hydroxide No None No No No No

Starter 40 (P359.00)0651-950

Sodium hydroxide No None No No No No

P360.00 Liquefied Propane Gas No Odourless No No No No

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16. Financial Commitment and Liabilities As previously expressed Pauwels Trafo Ireland are committed to comply with the

requirements as set out by the Integrated Pollution Prevention and Control License. We have a

designated Environmental Department and fully trained Environmental operators. We achieved

registration to the Environmental Standard ISO 14001 in 2000.The implementation of a recognized

environmental management system was in response to the growing global awareness of the

environment and the serious detrimental effect we all have on the environment in which we live. We

have also come to recognize the huge financial gain there is to implementing such a standard in

waste minimization and control coupled with higher environmental standards in the workplace.

In recognition of these gains, Pauwels wish to continually promote the growth of such

standards among its suppliers and to reward willing companies with continued custom.

As informed to the Agency in March 2005 our company was taken-over by Crompton

Greaves Ltd – an industrial conglomerate based in India. Our parent company is a very well

established firm with operations in 9 countries throughout the world. The business base for Pauwels

is strong and at least 50% of our current business coming from Renewable Energy Sector.

The financial status of the company is strong enough to guarantee funds for any environmental

restorations, which could be identified as a result of plant activities. We do not expect to suffer from

the current Economical Downturn.

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ref: letter – 25 june 2008 p0106-02 · 2013-07-26 · ref: letter – 25 june 2008 p0106-02 page...

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